Epstein Data Wiki

Bennet J. Moskowitz

Properties2
tagsperson, lawyer, litigation, new-york, epstein-estate, troutman-sanders
aliasesBennet Moskowitz, Moskowitz, Bennet J., B J Moskowitz, B. Moskowitz, BJM

58 min read

ProfessionLitigator. Troutman Sanders LLP invoices in the release are submitted in his name from a New York office12
Client fileEpstein was client 238227 at Troutman Sanders. The firm’s own remittance instructions print “Reference Attorney: B J Moskowitz” and “Reference Client: 238227”3
Earliest document26 August 2009, a message from Epstein’s assistant relaying “From Bennet Moskowitz: I am available between 1-3:00 to speak today.”4
Billing rate$265.00 an hour in December 2010; $595.00 an hour in 201825
Later roleCounsel to Darren K. Indyke and Richard D. Kahn as co-executors of the Estate of Jeffrey E. Epstein, with sworn declarations dated 2018, 2019 and 20216789
Estate litigationCounsel of record for the co-executors in at least seven parallel Southern District of New York actions brought by women suing the estate, 2019-202110
Signed positions6 January 2019, a response not opposing the unsealing of appellate briefs subject to redaction of alleged victims’ identities, signed with Martin G. Weinberg11; 3 December 2019, the letter answering what the estate was worth12
NotNot Bruce W. Moskowitz, the West Palm Beach physician, who is a different man with a much larger footprint in the same release

Bennet J. Moskowitz is a New York litigator whose name is printed on Jeffrey Epstein’s legal bills, on the wire instructions that paid them, and, after Epstein’s death, on sworn declarations filed for the executors of his estate in federal suits brought against it, including suits brought by women who said Epstein abused them. He is not accused of wrongdoing anywhere in the released files, and the one adverse characterisation of him that the release contains is contradicted by four documents in the same release, two of them his own. What the files establish is a professional relationship that ran for at least twelve years, from a request for a telephone call in August 2009 to declarations filed in 2021, and a set of documents that let that relationship be traced to the cent. Twice the record carries his own signature over a substantive position: in January 2019 he signed, with Martin Weinberg, a four-line filing in which Epstein did not oppose the unsealing of appellate briefs “subject to the proposed redactions of any alleged victim identities”; and in December 2019 he signed the letter in which the executors told claimants’ counsel that the total value of the estate could not be stated.1112

The spine of the record is a number rather than a name. Epstein was client 238227 at Troutman Sanders LLP, and Troutman Sanders instructed anyone paying its bills to quote “Reference Attorney: B J Moskowitz.”3 Because Epstein’s bookkeepers followed that instruction, the client-matter reference travelled onto every wire, and the number now reaches 74 documents in the release of which 73 carry no forename for him at all.13 A reader searching for the man finds a fraction of the file; a reader searching for the number finds the payments.

The two Moskowitzes

This page exists alongside Bruce W. Moskowitz, and the two men must not be run together. But “two” is wrong: the release carries at least four people of this surname, and the desk has been able to establish that two of them are distinct without being able to establish anything about whether they are related.

The four are this litigator; Bruce W. Moskowitz, the West Palm Beach physician; Aaron Moskowitz, who appears in about 31 documents soliciting investment from Epstein and who is documented in the release as the physician’s son; and Norman A. Moscowitz, an attorney appearing in three electronic-notice service lists for an unrelated defendant.14

That the litigator and the physician are distinct people is settled, and settled cleanly: on seven sheets of Epstein’s own mass distribution lists, “Bennet Moskowitz Esq” and “Dr. Bruce Moskowitz” appear as separate, separately titled entries side by side.15 Whether they are related is not established by any document in the release, and this page does not assert that they are not.

The surname alone reaches 2,728 documents.13 Of those, forms naming Bruce reach about 1,268, and the frequent misspelling “Moscowitz” reaches a further 567.13 That C-spelling set is often said to be entirely the physician’s. It is not: of the 567, only 222 contain “Bruce” at all, 345 carry neither forename, and at least three are the attorney Norman A. Moscowitz.16 What is true, and is the useful rule, is that no Moscowitz in the release is this litigator: every C-spelling form of his name returns zero.16 Forms naming Bennet reach 561.13 The arithmetic leaves 773 surname documents carrying neither forename anywhere, which is the class where a careless reader will merge them.

The practical rule for anyone working in these files: a bare “Moskowitz” is more likely to be the physician than the lawyer, and a bare “Moscowitz” is never this lawyer. Where this page relies on a document that does not print a forename, it says so and says what else on the sheet establishes which man it is: in nearly every case, the client number 238227, the Troutman Sanders letterhead, or both.

Where his name is, and where it is not

Two forms of his name circulate in the release, and, unusually, neither contains the other.

Measured against the full-text index on 18 September 2026, count(distinct efta_number) over text_content: the phrase “Bennet Moskowitz” returns 343 documents. The phrase “Bennet J Moskowitz” returns 414. Their intersection is only 196, and their union is 561.13 That is about 218 documents reachable only through the middle initial and about 147 reachable only without it. Neither form is a superset. A search on either one alone misses between a quarter and a third of his file.

And the form that matters most contains no forename at all. “B J Moskowitz” returns 43 documents, of which 42 lie outside the union above, because it is the form the client-matter number rides on. Every payment instrument in the release reads “B J Moskowitz Client # 238227”, and no phrase query built on “Bennet” reaches any of them.13

Four further forms exist. The double-t misspelling “Bennett Moskowitz” returns 22 documents, of which 17 lie outside the union above. The reversed field order “Moskowitz Bennet”, the shape a service list or an index prints, returns 342, but only 13 of those lie outside the two plain forms. “B Moskowitz” returns 10, of which 7 are new. And his full middle name appears in federal docket records as “Bennet Jerome Moskowitz”, which returns 5.13

The union of every name form is 622 documents, not the 561 the two obvious forms give. Adding the firm conjunction, the bare surname together with the firm name, which returns 493 documents of which 72 lie outside every forename form, and then the client number, gives a floor of 672.13

Three further observations, each of which cost a search to learn:

  • The client-matter number is the better key. 238227 returns 74 documents, and 73 of them contain no instance of “Bennet” anywhere.13 The payments are indexed by the number, not the man.
  • His forename is heavily contaminated, but not entirely. “Bennet” alone returns 669 documents, of which 90 contain no “Moskowitz” at all.13 Most of those 90 are other people: a United States senator, an FBI special agent in charge, a character in a nineteenth-century novel quoted in an essay, a named aircraft, and a run of mangled brokerage-statement boilerplate. But nine of the ninety are him, documents that use his forename without his surname anywhere, so the bucket cannot simply be discarded as noise.13
  • One subject line in the release drops the final letter of his surname entirely, reading “Bennet Moskowit.”17

August 2009: the first document

The earliest document in the release that concerns him is not his own. On 26 August 2009 Epstein’s assistant Lesley Groff wrote to Epstein under the subject line “Bennet Moskowitz”, relaying a message in the first person:

From Bennet Moskowitz:

I am available between 1-3:00 to speak today. If you could pin point a time I will have my partner on the call as well.4

Beneath the message the sheet carries two lines each consisting of an opening parenthesis, a solid black redaction bar, and then a label, “Office)” and “cell)”. The labels print; the values are barred, not missing. The text layer drops the barred region, which is why an extraction shows bare labels and reads like an absence. Those are contact values and would not be reproduced here in any event.

The relay matters for two reasons. It places the relationship almost a year before the first payment this page can document, and it shows the shape the relationship had from the beginning: Moskowitz did not write to Epstein directly, he asked Epstein’s staff to find him a slot, and he brought a partner.

It should be called the earliest Moskowitz document located in the release rather than his first contact with Epstein; a search across the pre-2009 years returned 44 documents and every one opened was a later document containing an incidental year token.18 And there is a gap that is itself a finding: first contact August 2009, first billed invoice month on the contemporaneous fee ledger May 2010, first wire August 2010. Nine months separate the first contact from the earliest billing the release shows, and nothing in the release fills it.

A year later the same assistant wrote again, on 13 September 2010:

Bennet is hoping to schedule a conf. call with you, Steve Reinhart, Darren and Bruce Tetteilbaum re NY attorney information today if possible?

Darren has called for you a few times as well..17

The spellings are as printed. “Tetteilbaum” is very likely Teitelbaum but the sheet prints “Tetteilbaum” and it is not silently corrected here. “Steve Reinhart” is left as printed and flagged: a Bruce Reinhart appears elsewhere in the release as an Epstein-side legal payee, and whether the message names a different person or is the sender’s error has not been settled.17

“Darren” is Darren Indyke, Epstein’s lawyer. The message is dated three days before a wire of $20,716.05 left Epstein’s account for Troutman Sanders against Moskowitz’s reference.19

The file: client 238227

Two Troutman Sanders invoices in the release bracket the relationship, and their matter numbers are the clearest measure of its length.

The earlier is dated 3 December 2010, invoice number 1319153, file number 238227.000015’s distant predecessor 238227.000001. Its subject line reads “Zwirn/Dubin dispute.” The timekeeper summary lists two people: Bourguignon at $525.00 an hour for 0.2 hours, and “BJM Moskowitz” at $265.00 an hour, his hours barred on the sheet.2 The release does not state either lawyer’s title, so the higher rate is not described here as a partner’s.

⚠ The .000001 suffix does not mean this was the first invoice. The same document lists four earlier Troutman Sanders invoices on Epstein’s account, and none of those four is in the release.2 Counting across both invoices, the release carries two of at least eighteen invoices the documents themselves reference. Any statement about when the billing started rests on a ledger, not on the invoice numbering. Daniel Zwirn and the D.B. Zwirn entities were adverse parties in an arbitration in which Epstein’s Financial Trust Company was a claimant; that arbitration is described on the company’s own page.

The later invoice is dated 17 October 2018, invoice number 2040188, file number 238227.000015, and is addressed to Jeffrey Epstein at “Darren K. Indyke, PLLC”, 575 Lexington Avenue, 4th Floor. (Those lines are interleaved with a second column on the sheet, so they are described here rather than quoted. The sheet carries no “care of” or “c/o” wording; that is the desk’s characterisation of an address block, not the document’s language.) It is marked “Submitted by B J Moskowitz.” Its subject line reads “Gerber vs. The Financial Trust Co.”1

Between the two, then: fifteen matter numbers and eight years on one client file. Over the same span his rate rose from $265.00 to $595.00 an hour, ending above the rate the other lawyer on the 2010 matter had charged.25 No intermediate rate has been located, so the arc is two points and a gap, not a curve.

The payments

Epstein’s bookkeepers paid Troutman Sanders by wire, and every wire carried the same reference. The bank statements and the wire-request memoranda record thirteen distinct JPMorgan wires between August 2010 and June 2013, all to Troutman Sanders LLP, all referenced to “B J Moskowitz — Client 238227”, together totalling $113,465.97.20

The series does not end there. Two further payments on the same client file, from a Deutsche Bank account in Epstein’s name, are in the release and are invisible to a search for the client number because those statement lines carry no reference field at all: $450.00 on 4 February 2014 and $48,960.59 on 31 October 2018.2122 Fifteen distinct transactions, $162,876.56, across at least eighty-four documents.20

The apparent change of beneficiary bank in 2012 is an artefact of how the statements describe the route. Early rows post as “Fedwire Debit Via: Wachovia Bk NA GA/061000227” and later rows as “Via: Wells Fargo NA/121000248”, but the later rows continue “/Acc/Org CR Pty Recd Aba/061000227 Wachovia Bank NA of Georgia”, and every memorandum from August 2010 onward instructs the same beneficiary bank and the same Georgia routing number. The money went to one Troutman account throughout; only the description changed, around the acquisition of Wachovia.20

The amounts fall away sharply. The first is $25,000.00 on 5 August 2010; the smallest is $252.00 in November 2012; the last JPMorgan wire is $391.86 on 26 June 2013.2324 The first four carry no invoice number at all, the reference line reading simply “B J Moskowitz Client 238227”; from April 2011 onward each one names the invoices it settles.20

⚠ Two gaps in the instruments are findings rather than absences. There is no instruction document for the 24 April 2013 wire and none for the 31 October 2018 payment, where every other JPMorgan wire has at least one. And invoice 1319153, the December 2010 Zwirn/Dubin bill, appears only in its own document: no payment of its amount has been located, and whether it was ever paid is untested. The billing series therefore begins before the paying series does.20

One sheet is worth reading whole. The JPMorgan statement for the period 31 July to 31 August 2010 shows that on 5 August 2010 seven wires left the account in a single block, three of them to law firms:

BeneficiaryAmountReference as printed
Martin G Weinberg P C$50,000.00”IOLTA Ref RefJune And July Invoices”
Troutman Sanders LLP$25,000.00”Ref B J Moskowitz Client 238227”
Black Srebnick Kornspan and Stumpf P.A.$25,000.00”Statement 57/Acc/Trust Acct No 2 No Name Given”

The $50,000 above the $25,000 is Martin Weinberg’s trust account.23 On one morning, on one sheet, Epstein’s household wired six figures to three separate defence firms and booked all of it as ordinary account activity. The statement’s own footer calls the sheet “Page 2 of 10.”23

Who moved the money

The wires were not initiated by Moskowitz or by Epstein. They were initiated by memoranda on “JEFFREY E. EPSTEIN” letterhead, faxed to named officers at JPMorgan, instructing the bank to “Please wire Twenty Five Thousand Dollars & 00/100 ($25,000.00) from the above account” and setting out the beneficiary bank, the account and the reference.25 Several close: “Please call Rich Kahn with the Fed Reference number.” That line is boilerplate, appearing on nearly twenty thousand documents in the release including wire instructions having nothing to do with this file, so it marks Epstein’s standard treasury practice and not anything about this payee.252627 Kahn is Richard Kahn, Epstein’s senior accountant, later, with Indyke, co-executor of his estate and Moskowitz’s client.

Two men signed them, and they split by date rather than by amount. Of the nine instruments whose author has been read at the image, seven are from Harry Beller and two from Darren Indyke, Indyke’s being the first in the series and the January 2011 payment of the invoice Kahn had flagged.28 The February 2014 Deutsche Bank authorisation is Beller’s, over a wet signature and dated in his own hand.21

Item (h)

On 18 January 2011 Kahn sent Epstein an email headed “re: Open Items”, a lettered list of household and business items awaiting Epstein’s attention. It runs from staff car repairs to health-insurance renewals to a fuel deal in St Thomas. Item (h) reads:

h) Bennet Moskowitz open invoice totaling 8,117.51 (pd to date: 65,716.05)2930

The parenthesis can be checked against the bank. The three payments to Troutman Sanders against Moskowitz’s reference that preceded this email were $25,000.00 on 5 August 2010, $20,716.05 on 16 September 2010 and $20,000.00 on 2 November 2010.231931 They sum to exactly $65,716.05. Kahn’s running total is reproducible to the cent from bank records in the same release, which is unusual enough to be worth stating plainly: it confirms both that the list is accurate and that the three wires are the complete set to that date.

Eight days later, on 26 January 2011, a memorandum went to JPMorgan instructing it to wire “Eight Thousand One Hundred Seventeen Dollars & 51/100 ($8,117.51)” to Troutman Sanders against the same reference, and the statement for January 2011 records the debit.3233

And a second, independent, contemporaneous document confirms the figure to the cent. A spreadsheet headed “Jeffrey Epstein — Outstanding Legal Invoices”, whose latest invoice month is October 2010, carries a Troutman Sanders row reading: total billed $82,833.59, written off or returned −$10,968.10, revised total billed $71,865.49, total paid $65,716.05, balance outstanding $6,149.44, and, in a final column, 8.56%.34 Three arithmetic checks hold: 82,833.59 − 10,968.10 = 71,865.49; 71,865.49 − 65,716.05 = 6,149.44; and on the itemised sheet the credits of $76,684.15 less the $10,968.10 write-off leave exactly $65,716.05. So the write-off was not a payment, and the cash actually paid is exactly the three wires.34

The ledger also dates the application of each wire: $25,000.00 against the June invoice, $20,716.05 against July, $20,000.00 against September. Each wire paid the preceding month’s bill.34 Two cautions. The ledger attributes the $65,716.05 to Troutman Sanders as a firm, not to Moskowitz personally, and it should be read that way. And the two documents are snapshots of a running account at different moments, not two views of one balance: the ledger’s total billed exceeds the paid-plus-open figure from the January e-mail by about nine thousand dollars, and its outstanding balance is not the $8,117.51 of item (h). The figure that reconciles to the cent is the total paid, and that is the one this page rests on.34

Two things follow. The first is about the man: his invoice was tracked on the same list, in the same register, as a household car repair, health-insurance renewals and payroll reviews. Legal fees were administered as domestic expenditure. The second is about the record, and the precise statement is narrower than it first appears. Neither copy of Kahn’s e-mail can be found by searching for the open-invoice figure; both can be found by searching for the paid-to-date figure beside it. One copy’s text layer renders the first figure “8,1 17 5 1”, spaces inserted and the decimal point lost, while the printed page is clean and legible, which makes it an extraction defect.29 The other prints ”=,117.51” on the page itself: that document is a corrupted print-out of the HTML e-mail, with quoted-printable soft breaks and broken tags baked in before the PDF was made, each stray ”=” having eaten the character after it, and the same damage recurs throughout the sheet.30 These are two different kinds of defect and only the first is an extraction finding. The general lesson is cheap and reusable: when a figure will not resolve, search the figure next to it.

2018: the Gerber defence

His involvement with the Towers matter begins earlier than the litigation. On 1 July 2016, when Steven Hoffenberg withdrew an earlier suit against Epstein, the withdrawal letter to the court was copied to three people: Hoffenberg himself, another lawyer, and “Bennet J. Moskowitz, Esq.”35 Two years later he would be the name on the motion to dismiss the successor case.

In August 2018 Marvin Gerber and Kalma Koenig, noteholders of Towers Financial Corporation, sued Epstein and his Financial Trust Company in the Southern District of New York, pleading harm from what they called a Ponzi scheme perpetrated by Epstein as an uncharged co-conspirator of Steven Hoffenberg. Moskowitz ran the defence, and the invoice records what he did, day by day, in his own billing narrative.

His first entry is dated 27 August 2018:

Analyze complaint and compare to prior complaint filed by Hoffenberg; draft email memo to D. Indyke analyzing complaint and recommending litigation strategies36

His second, two days later, records analysing the case filings, a “telephone call with D. Indyke regarding status of service of the complaint”, and beginning to outline a motion to dismiss.36 The entries then run continuously for a fortnight through drafting and redrafting the motion and the memorandum of law, researching the statute of limitations, fraudulent concealment and the discovery rule, and, on 9 September, “analyze news articles, court filings and other materials concerning Hoffenberg for use in motion to dismiss.”36

The invoice’s timekeeper summary prints his own contribution exactly: “BJM Moskowitz 27.0 595.00 16,065.00.” Six other timekeepers billed the matter, the largest being Molly S. DiRago at 48.1 hours and $460.00 an hour. The summary’s rows are ordered alphabetically by surname, not by hours or amount, and his is the sixth of seven. Fees came to $40,017.00 through 30 September and costs to $8,943.59 through 17 October, for a total of $48,960.59.51

The motion to dismiss was filed on 14 September 2018 over his signature, supported by a sworn declaration of Bennet J. Moskowitz dated the same day37, which attached as its Exhibit A a 1997 decision of the same court in United States v. Hoffenberg, No. 94-cr-213. That opinion does not name Epstein anywhere in its eleven pages, which is worth stating because the brief cited it against a complaint whose theory was that Epstein was Hoffenberg’s uncharged co-conspirator.6 Twenty-one days later the plaintiffs dismissed their case voluntarily, without prejudice, on 5 October 2018, twelve days before the invoice was issued.38

And the invoice was paid fourteen days after it was issued. A Deutsche Bank statement records an outgoing transfer of $48,960.59 to Wells Fargo for Troutman Sanders on 31 October 2018, which is the exact total of invoice 2040188, and a figure that appears on only two documents in the entire release, namely the statement and the invoice.221

Two sheets in the release carry the Gerber caption above the legend “DRAFT; PRIVILEGED; ATTORNEY WORK PRODUCT.”3940 Whatever the drafts contain, the legend is printed on the face of the produced page. That is a producer-side exposure, and this desk records it rather than reasoning about it.

January 2019: the unsealing response

Seven months before Epstein died, and while he was alive and represented, Moskowitz signed a filing on his behalf that bears directly on how the rest of this page should be read.

On 6 January 2019, in App. Div. No. 6081, a “Response to Motion to Unseal Appellate Briefs” was filed for Epstein and signed for Troutman Sanders LLP by Bennet J. Moskowitz and by Martin G. Weinberg. It is four lines long. Epstein, it says, “does not oppose NYP Holding, Inc’s request to unseal the appellate briefs in the above-captioned matter subject to the proposed redactions of any alleged victim identities, see Post Memorandum at 14, so that the unsealing is consistent with N.Y. Civil Rights Law § 50-b.”11

Section 50-b of the New York Civil Rights Law is the provision that shields the identity of a sex-offence victim. The filing Moskowitz signed both declined to oppose disclosure and asked that alleged victims’ names be withheld, citing that statute by name. The episode is set out in full at NYP Holdings, where the record shows that the man whose brief was under seal did not object to its release while the prosecutor’s office did.

This is also the one document that connects him to Martin Weinberg professionally. Their names appear together elsewhere in the release only as adjacent debits on a bank statement, which establishes nothing beyond the fact that Epstein paid several firms on one morning; the co-signature is a real link and the wire adjacency is not.23

December 2019: what the estate was worth

The longest passage of his own writing in the release is a letter he signed on 3 December 2019, answering two questions that Sigrid S. McCawley of Boies Schiller Flexner had put to the executors on 22 November on behalf of claimants.12

Asked what the total value of Epstein’s estate was, the letter pointed to the figure in the probate petition and then said the total could not be calculated. The estate, it said, “is subject to substantial potential liabilities in an undetermined amount, which makes it impossible to accurately calculate the total value of the Estate”: estate taxes “in at least two jurisdictions, the United States and France”; the statement that “the United States Department of Justice has indicated that it may seek civil forfeiture of properties held by the Estate”; and seventeen lawsuits already lodged in New York state and federal courts, with the number and size of future claims unknown.12 It concludes:

For these reasons, it is simply not possible at present for the Co-Executors to state the total value of the Estate.41

The letter is signed by him and copied to fourteen lawyers.42 Its answer to the second question, about money set aside to compensate victims, belongs to the record of the compensation programme and is covered at the Epstein estate.

Counsel to the executors

Epstein died in August 2019. Indyke and Kahn became co-executors of his estate, and from 2019 Moskowitz appears as their counsel, filing sworn declarations in federal litigation brought against the estate.

The release carries five declarations of his, and their purposes are almost all the same: to place a document before a court.43

DatedActionWhat it does
14 September 2018Gerber, No. 1:18-cv-07580Exhibits to the motion to dismiss. Present only as a privileged internal draft; no as-filed copy is in the release6
29 November 2019No. 1:19-cv-07625”The sole purpose … is to place before the Court a copy of Plaintiff’s First Amended Complaint”7
23 December 2019Jane Doe 17, No. 1:19-cv-09610Places the plaintiff’s complaint before the court8
11 May 2020No. 1:20-cv-00484Places two earlier opinions and orders in evidence44
13 August 2021No. 1:20-cv-02365Supports the co-executors’ statement on the plaintiff’s application to proceed anonymously9

In the last of these, both the statement and his declaration were filed twice over on the same day, an unredacted version under seal and a redacted version publicly, and the exhibits to his declaration were filed entirely under seal.45

One passage in that filing is worth setting out with care, because the desk first read it wrongly and so did the pass that checked it. A footnote to the covering letter asserts, of the compensation programme the co-executors funded:

No claimant who participated in the Program is bound by any rules of confidentiality — to the contrary, they are free to tell their stories publicly.46

That sentence carries no citation and no exhibit on the face of the filing.46 His declaration is cited to the adjacent sentence, the one giving the programme’s size, “nearly $125 million to approximately 150 eligible claimants”, and the description of what his declaration authenticates is itself barred, running to a visible closing parenthesis, so what it certified cannot be established.46 So the estate did assert in terms that programme claimants were not gagged, and his declaration was not the evidence offered for it, a distinction worth drawing because the opposite is the easier and wronger reading.

But uncited is not unsupported, and the assertion is borne out elsewhere. The compensation programme’s own protocol provides that the release “will not impose any rules of confidentiality on claimants, who are expressly permitted to discuss their allegations without restriction, should they choose”, a term set out with its citation at the Epstein Victims’ Compensation Program.47 The footnote lacked a citation; the proposition did not lack a basis, and a reader should not take the missing citation for a missing fact.

The plaintiffs in this litigation are identified in the public record only by pseudonym. This page keeps it that way and goes no further into any of these cases than the estate’s own filings require.

The anonymity record, October to December 2019

This is the part of the record most likely to be got wrong, and the desk drafted it wrongly before a verification pass went looking for his own filings. The account below rests on eleven documents from a single Southern District of New York docket, Jane Doe v. Indyke and Kahn, No. 1:19-cv-08673, which sits in one contiguous run in the release.

What the release first appears to say

On 31 October 2019, lawyers at Kaplan Hecker & Fink LLP wrote to Judge Katherine Polk Failla. Two copies are in the release, one stamped “MEMO ENDORSED” and filed the next day with Judge Failla’s order setting a conference for 7 November 2019.4849 The letter opens:

We write in response to the letter dated October 29, 2019, from Bennet Moskowitz, counsel for Defendants, representatives of the Estate of Jeffrey Epstein (ECF No. 13), in which Mr. Moskowitz argues that the Order that Judge Castel issued granting the plaintiff’s motion for leave to proceed anonymously in Katlyn Doe v. Darren Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein, et al., 1:19-cv-7771, was issued ex parte, prior to Defendants’ appearance in that case.48

It continues:

It is not clear to us why Defendants would object to Plaintiff, a childhood victim of sexual assault, proceeding pseudonymously in this case, particularly when so many other courts have granted motions to proceed under pseudonym in analogous circumstances.48

and adds: “It is also worth noting that although Mr. Moskowitz had 14 days to seek reconsideration of Judge Castel’s ruling pursuant to Rule 6.3 of the Local Rules, he failed to do so.”48

What his own letter says

His letter is in the release, and it asks for nothing. It is a single page, Document 13, filed 29 October 2019 on Troutman Sanders letterhead over “s/Bennet J. Moskowitz”.50 In full, but for the address block:

We represent Darren ▮. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, “Defendants”), in the referenced action. We write to clarify the record in response to Plaintiff’s counsel’s October 15, 2019 letter (ECF # 12) attaching a copy of an Order that the Hon. P. Kevin Castel issued in Katlyn Doe v. Darren ▮. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate of Jeffrey E. Epstein, et al., 1:19-cv-0777. Specifically, Judge Castel issued the aforementioned Order ex parte, before our clients timely appeared in Katlyn Doe.

In accordance with Your Honor’s Order dated October 7, 2019 (ECF #10), Defendants will respond to Plaintiff’s Motion to Proceed Under Pseudonym (ECF #3) by November 15, 2019.

Thank you for your attention to this matter.50

No motion, no objection, no application, no request that the plaintiff be named. Two factual paragraphs and a thank-you, the second of which points at the court’s own schedule for answering the pseudonymity motion. The word “timely” is his, and it is doing work: he is asserting his clients were not in default.

What he said when the characterisation was put to him

Six days later, in Document 20, he answered it on the docket and by name:

Plaintiff’s counsel … misstates Defendants’ position on Plaintiff’s Motion to Proceed Under Pseudonym (ECF# 3)51

and:

Ms. Kaplan incorrectly asserts that Defendants object to Plaintiff’s Motion to Proceed Under Pseudonym. To the contrary … Defendants have no objection … We never suggested otherwise to Ms. Kaplan.51

Then, in the memorandum of law he actually filed on the motion, on 15 November 2019, over his signature:

Defendants do not object to Plaintiff proceeding under a pseudonym to prevent the disclosure of her identity to the general public. However, this response is necessary for two separate reasons.

First, Plaintiff’s Motion asserts numerous unproven statements, couched as facts already in evidence, as well as conclusions of law. Defendants object to these unproven and conclusory assertions. In any event, the Court does not need to consider such assertions to resolve Plaintiff’s Motion.

Second, it is imperative that Plaintiff’s desire to shield her identity from the general public not come at the expense of Defendants’ fundamental right to fully and fairly respond to Plaintiff’s allegations in her Complaint.52

What he did do, which is a real dispute and not a nothing

Instead of simply consenting, he asked the court to enter his own proposed order, filed as Document 31-1 and headed “ORDER ON PLAINTIFF’S ANONYMITY”.53 That order protects anonymity: the plaintiff’s identity goes to defence counsel only, within three days; filings are sealed with publicly filed redacted copies. Its third paragraph is the contested one. It would have provided that “Defendants shall not be permitted to further disclose Plaintiff’s identity except as necessary to defend against this action.”53

The plaintiff’s reply, Document 34, conceded the non-objection and attacked that paragraph:

Defendants assert that they do not object to Plaintiff proceeding under a pseudonym. (See Resp. at I.) However, they ask the Court to enter an order … that would render the protections of pseudonymous proceedings meaningless54

because, it argued, the carve-out “vests in Defendants the unilateral discretion to disclose Plaintiff’s identity even further whenever Defendants determine such disclosure is ‘necessary to defend against this action.’”54 The same reply also withdrew the premise of the Rule 6.3 accusation, stating: “Notably, Defendants have not objected to Judge Castel’s Order.”55 A party that has not objected to an order has no occasion to seek reconsideration of it. And the date his letter pointed to was not one he had chosen: the plaintiff had consented to it on 24 September 2019.56

How it ended

By a joint stipulation he signed. Document 38, dated 13 December 2019 and entered as an order on 18 December by Magistrate Judge Debra Freeman, is headed “JOINT STIPULATION AND [PROPOSED] ORDER ON PLAINTIFF’S ANONYMITY” and carries both sides’ signature blocks on one instrument, his over “TROUTMAN SANDERS LLP, Attorneys for Defendants Darren K. Indyke and Richard D. Kahn”.57

The entered order is substantially his draft with the contested paragraph replaced by the plaintiff’s mechanism. Three paragraphs carry over from his version; the disclosure paragraph is tightened from “Defendants and any attorneys” to counsel of record and their staff; and the “as necessary to defend” carve-out is gone, replaced by a requirement that any further recipient “first execute a non-disclosure agreement, in a form agreed to by the parties”, with Defendants to “maintain a list of all such persons to whom Plaintiff’s identity is disclosed and copies of the executed non-disclosure agreements, all of which are subject to in camera inspection.”57

So the sequence runs the other way from the letter that opens this section. He was characterised on 31 October as objecting to a survivor’s pseudonymity; he denied it on 5 November, disclaimed it in a signed brief on 15 November, was conceded on 19 November never to have objected to the underlying order, and on 13 December signed the stipulation that protected her anonymity. An account that stopped at the 31 October letter would not be incomplete; it would be the reverse of the documented outcome.

Why the desk nearly published the opposite

Worth recording, because it is a search failure with a mechanism. Every obvious query for his letter fails on it. It never mentions reconsideration or Rule 6.3. It does not refer to itself as ECF No. 13. It miscites the other docket as 1:19-cv-0777, a dropped digit, so a search on the correct number 19-cv-7771 reaches only his opponent’s filings. And the phrase “ex parte”, which prints correctly on his page, is rendered “ex pane” in the text layer of both Kaplan Hecker copies, so no query bridges the two documents.5048 It was found instead by docket adjacency: the whole 08673 run occupies consecutive identifiers, so Document 13 sits immediately before Document 14.

The miscite is not a one-off. The same dropped digit appears in a letter he filed the same day in a different action before a different judge, in wording otherwise almost identical, which shows it was a template typo propagated across his parallel letters rather than an artefact of one scan.58

The separate preservation allegation, and its answer

The 31 October letter also alleged that “Defendants have failed to confirm that they are properly preserving relevant documents.” The sentence has a lead-in and a tail, and the tail concedes something:

In addition, we would like to request a conference in this matter. Despite multiple rounds of email correspondence and an attempt to meet and confer, Defendants have failed to confirm that they are properly preserving relevant documents. See Ex. A (parties’ correspondence). Although Defendants are not obligated to respond to the Complaint until November 15, 2019, given the risks of spoliation, we respectfully request that the Court calendar a conference in which this issue can be discussed with the Court as soon as possible.48

His answer is in the release, and so is the underlying correspondence, filed as Exhibit A to the letter that complained about it.59 In Document 20 he wrote that the request was based “on a U.K. tabloid article that we already advised Plaintiff’s counsel is, to the extent it suggests spoliation has occurred, false”; that “We have also advised Ms. Kaplan on multiple occasions, including in writing, that the Co-Executors are abiding by their discovery obligations”; and that the letter motion had been submitted “without first meeting and conferring with us as we requested”, he having been “at an arbitration hearing in Southfield, Michigan (which Ms. Kaplan was aware of)”.51

The one time he asked a court to undo an anonymity order

The record above should not be read as making him a bystander on this question, because in a different case he moved against an anonymity order that had already been granted.

On 20 November 2019, in Jane Doe 17 v. Indyke and Kahn, No. 1:19-cv-09610, he filed a letter over his signature asking the court to vacate its own order granting the plaintiff’s motion to proceed anonymously, which had been entered twelve days earlier:60

We write to respectfully request that the Court vacate its Order dated November 8, 2019 (ECF #25) granting Plaintiff’s Motion to Proceed Anonymously (the “Motion”) (ECF #24) filed earlier that day. The basis for this request is that Your Honor’s Order dated November 5, 2019 (ECF #21) provides Defendants through December 21, 2019 to respond to Plaintiff’s Motion.

Defendants did not have an opportunity to respond to Plaintiff’s Motion. Defendants do not object to Plaintiff proceeding anonymously to prevent the disclosure of her identity to the general public. However, Defendants seek the opportunity to be heard so the relief granted on Plaintiff’s Motion ensures Plaintiff may protect her anonymity without jeopardizing Defendants’ fundamental right to fully and fairly defend against this action.

Plaintiffs’ counsel does not consent to this request.60

Stated precisely: he asked a court to vacate an order protecting a survivor’s anonymity, on the procedural ground that he had not been heard and that the court’s own schedule gave him a month more to answer, while expressly disclaiming any objection to her proceeding anonymously, and over the plaintiff’s refusal to consent. That is his own signed filing rather than anyone’s characterisation of him, and it is the sharpest thing the release supports about his conduct as counsel.

What is not established

  • He is almost never an e-mail sender. Only three documents carry him in a “from” position, and in two of those the “from” is a relay by Epstein’s assistant quoting him.417 But his own voice is not scarce: it reaches the record through filings and letters rather than correspondence, and the release carries six of them quoted at length above.
  • Whether the two Moskowitzes are related is not established by any document in the release. That they are distinct people is.15
  • The payment series is a floor. Fifteen transactions are identified and two of them carry no client reference at all, which is why the client-number search understates the total. A sixteenth may exist in the same reference-free form.20
  • Invoice 1319153 may never have been paid. No payment of its amount has been located.20
  • Sixteen invoices the documents themselves reference are not in the release, so no statement here about the shape of the billing over time can be more than an interpolation between two surviving invoices and one ledger.234
  • What was sealed in the filing where a statement and his declaration were filed under seal and publicly at once is not established.45
  • Whether the 2021 action in which he declared was decided is not addressed here; the release shows it was stayed.
  • No document in the release accuses him of anything. He was a litigator doing litigation for a paying client, and later for that client’s executors, and on the one question where the release contains an accusation against him, namely that he opposed a survivor’s anonymity, the documents refute it, including two of his own and one of his opponent’s.

Footnotes

Footnotes

  1. Troutman Sanders LLP invoice, invoice date 17 October 2018, invoice number 2040188, file number 238227.000015, re “Gerber vs. The Financial Trust Co.”, submitted by B J Moskowitz, addressed to Jeffrey Epstein care of Darren K. Indyke. PLLC, 575 Lexington Avenue, 4th Floor, New York. EFTA00804463 p.1. Fees for professional services rendered through 30 September 2018, $40,017.00; costs and expenses through 17 October 2018, $8,943.59; total $48,960.59. The run is 7 sheets. An identity-number-class value printed on the sheet is not reproduced here. This is the same invoice cited at Towers Financial Corporation. ↩ ↩2 ↩3 ↩4

  2. Troutman Sanders LLP invoice, invoice date 3 December 2010, invoice number 1319153, file number 238227.000001, re “Zwirn/Dubin dispute”, submitted by B J Moskowitz. EFTA01083374 pp.1-2. The timekeeper summary on p.2 prints “RLB Bourguignon 0.2 525.00 105.00” and, for “BJM Moskowitz”, a rate of 265.00 and an amount of 1,298.50 with the hours figure covered by a bar — redacted on the page, not mangled in the extraction. The implied 4.9 hours is arithmetic and is not printed anywhere. The same document lists four earlier Troutman Sanders invoices on the account, none of which is in the release. The run is 3 sheets. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  3. Payment instructions printed on the same invoice. EFTA00804463 p.7. Prints “Reference Attorney: B J Moskowitz” and “Reference Client: 238227” beneath the firm’s banking details. The equivalent page of the 2010 invoice prints the same two lines. EFTA01083374 p.3. ↩ ↩2

  4. Lesley Groff to Jeffrey Epstein, Wednesday 26 August 2009, 3:02:22 PM, subject “Bennet Moskowitz”. EFTA02435663 p.1. The sheet carries the labels “Office)” and “cell)” with nothing against them; whether the values are barred or simply absent from the extraction has not been settled at the image, and they are contact values that would not be reproduced either way. ↩ ↩2 ↩3

  5. Timekeeper time summary through 30 September 2018, same invoice. EFTA00804463 p.4. Prints “BJM Moskowitz 27.0 595.00 16,065.00”; also PC Cherry 0.3 at 215.00, MD Di Rago 48.1 at 460.00, ALG Genovese 0.4 at 475.00, SH Harris-Finkel 2.4 at 250.00, KM Molina 2.5 at 165.00, and TT Townsend whose rate is cut off in the extraction read here. ↩ ↩2 ↩3

  6. The declaration itself is in the release only as a privileged internal draft: EFTA00800143 pp.1-3, the sheet headed “DRAFT; PRIVILEGED; ATTORNEY WORK PRODUCT”. No as-filed copy was located, with positive controls run.43 It is cited in the signed memorandum of law as “the Declaration of Bennet J. Moskowitz (‘Moskowitz Decl.’) dated September 14, 2018 and submitted herewith”, the defined term being underlined on the image and mangled by the extraction. EFTA00802452 p.4, whose footnote 1 cites “U.S. v. Hoffenberg, 94-cr-213, 1997 WL 96563 (S.D.N.Y. Mar. 4, 1997)”. That opinion is EFTA01120694; it does not name Epstein on any of its eleven pages, established by full-text search and a page-by-page scan with controls firing on pp.1, 2, 3, 4, 7 and 10. ↩ ↩2 ↩3

  7. Notice of motion to dismiss a first amended complaint, resting on “the accompanying Memorandum of Law, the Declaration of Bennet J. Moskowitz dated November 29, 2019 and the exhibit thereto”, for “Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors”. EFTA02846195 p.1. A brief in the same matter records the plaintiff’s amended complaint as Exhibit A to that declaration. EFTA02846246 p.5. ↩ ↩2

  8. Notice of motion to dismiss a complaint, resting on “the accompanying Memorandum of Law, the Declaration of Bennet J. Moskowitz dated December 23, 2019 and the exhibit thereto”, for the same co-executor defendants. EFTA02738044 p.1. A brief in the same matter records the plaintiff’s complaint as attached to that declaration. EFTA02738046 p.5. ↩ ↩2

  9. Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey E. Epstein, No. 1:20-cv-02365-LJL-DCF (S.D.N.Y.), Document 34, filed 13 August 2021, headed as a declaration. EFTA02752622 p.1. The caption as printed spells the decedent’s forename “JEFFERY”; whether that is the filing or the extraction has not been settled at the image. That this is his declaration is under check. ↩ ↩2

  10. Documents locating him as counsel of record, all on Troutman letterhead over his name, in No. 1:19-cv-07625 (EFTA02846126 p.1), No. 1:19-cv-08673 (EFTA02750869 p.1 and the run at 50 to 57), No. 1:19-cv-09610 (EFTA02738030 p.1), No. 1:19-cv-10475 (EFTA02778310 p.1), No. 1:19-cv-10788 (EFTA02737246 p.1), No. 1:20-cv-00484 (EFTA02751930 p.1) and No. 1:20-cv-02365 (EFTA02752570 p.1). His own letter of 5 November 2019 footnotes six related actions and states the group “so far include 7 different plaintiffs and 20 different defendants”.51 Plaintiffs in these actions are identified in the public record by pseudonym or initials only, and this page goes no further than the case numbers. ↩

  11. “Response to Motion to Unseal Appellate Briefs”, App. Div. No. 6081, dated 6 January 2019, signed for Troutman Sanders LLP by Bennet J. Moskowitz and by Martin G. Weinberg. EFTA00801681 p.1. Read at the page image for the account at NYP Holdings, where the telephone and facsimile lines in both signature blocks are recorded as blacked out; those are contact values and are not reproduced here. The print reads “NYP Holding, Inc’s” and “Jeffery Epstein”, both as filed. ↩ ↩2 ↩3

  12. Letter of Bennet J. Moskowitz, Troutman Sanders LLP, to Sigrid S. McCawley, Boies Schiller Flexner LLP, 3 December 2019, “Re: Estate of Jeffrey E. Epstein”. EFTA00023230 p.1. Answering two questions put to the co-executors on 22 November 2019. The quotations in this section are taken from the account at the Epstein estate, which cites this letter across pp.1-3. ↩ ↩2 ↩3 ↩4

  13. Measurements taken 18 September 2026 against pages_fts over text_content in the desk’s full-text index of the release, counting distinct efta_number. Phrase queries: “Bennet Moskowitz” 343; “Bennet J Moskowitz” 414; their intersection 196 and union 561; “238227” 74, of which 73 contain no “Bennet” anywhere in the document; “Bennet” 669, of which 90 contain no “Moskowitz”; “Moskowitz” 2,728; “Moscowitz” 567; Bruce-naming forms 1,268; surname documents containing neither forename 773. Further forms: “Bennett Moskowitz” 22, of which 17 outside the 561 union; “Moskowitz Bennet” 342, of which 13 outside the two plain forms; “Moskowitz Bennett” 4. The firm conjunction "moskowitz" AND "troutman" returns 493, of which 72 outside every forename form. The union of all five name forms, the firm conjunction and the client number is 672, and the client number contributes 14 that nothing else in that set reaches. The three extra forms and the conjunction were taken from the homograph-subtraction arm published at Bruce Moskowitz, which had measured them for the opposite purpose. The index tokeniser splits on periods and commas, so “Bennet.Moskowitz” and “Moskowitz, Bennet” are not separate queries from the plain forms; “Bennet.Moskowitz” returns the same 343 as a control. Counts are of documents, not pages, and a document may hold many copies of the same sheet. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  14. Measurements taken 18 September 2026 on the same route as 13. “Aaron Moskowitz” returns 34 pages across 31 documents; two of them carry first-person references to his father on sheets also bearing the physician’s name and signature block. EFTA02645936 and EFTA00460277. “Norman A Moscowitz” returns 3 documents, all CM/ECF electronic-notice service lists for an unrelated corporate defendant; “Norman Moscowitz” without the middle initial returns 0, which is why the name is easily missed. EFTA01177324 p.9, EFTA00615543 p.11, EFTA01082066 p.7. ↩

  15. Seven sheets of Epstein’s own outbound distribution lists carry “Bennet Moskowitz Esq” and “Dr. Bruce Moskowitz” as separate entries, including a November 2018 gift circular and a related large copy list. EFTA00485416, EFTA00485426, EFTA00485434, EFTA00485440 p.2, EFTA00485518, EFTA00488116, EFTA00488136 p.2. ↩ ↩2

  16. Same route. Within the 567 documents returned by “Moscowitz”: 222 contain “Bruce”, 345 contain neither forename, and 3 contain “Bennet”. The three containing “Bennet” were opened and none is this litigator; one is a vendor-rendered message thread in which the physician is the speaker and “Bennet” is a bare forename in a message body with no surname, firm, client number or legal content attached to it anywhere on the sheet, read at 300 dpi and confirmed as one t. EFTA01613847 p.7, with the same message again at EFTA01210097 p.11; a third is an unrelated false positive on a different name. Every C-spelling form of the litigator’s name returns zero: “Bennet Moscowitz”, “Bennet J Moscowitz”, “B J Moscowitz” and “Moscowitz Bennet”. The 567-document set was additionally sampled by stratified selection of three documents per 100,000-identifier bucket across all 22 populated buckets, 66 of 567, and no litigator document was found in the sample. ↩ ↩2

  17. Lesley Groff to Jeffrey Epstein, Monday 13 September 2010, 8:49:08 PM, subject as extracted “Bennet Moskowit again”. EFTA02422562 p.1. Whether the missing final letter is in the subject line itself or is an artefact of the text extraction has not been settled at the image. The spellings “Steve Reinhart” and “Bruce Tetteilbaum” are as extracted and are likely mangled. ↩ ↩2 ↩3 ↩4

  18. Bounded absence, stated as such. Positive control: “Bennet Moskowitz” OR “Bennet J Moskowitz” returns 776 pages across 561 documents. The probe ("Bennet Moskowitz" OR "Bennet J Moskowitz" OR "Moskowitz Bennet") AND (2004 OR 2005 OR 2006 OR 2007 OR 2008) returns 44 documents; those opened are all later documents containing an incidental year token, including 2019-2020 press-clip compilations and the January 2011 Kahn e-mail, which mentions a 2004 vehicle. The corpus does not carry indexed document dates, so this is reported as “the earliest located”, never as a first contact. ↩

  19. JPMorgan statement, period 1 September 2010 to 30 September 2010. EFTA01483256 p.1. Records a $20,716.05 fedwire debit on 16 September 2010 to “Troutman Sanders Up” referenced “Ref: Ref B J Moskowitz Client 238227”. ↩ ↩2

  20. Independently enumerated twice, keyed on the Fedwire Imad/Trn pair, which is unique per transaction; figures read from the scanned images or from a layout-preserving extraction of the scans, because the corpus text layer does not preserve the amount and balance columns. Thirteen JPMorgan wires: $25,000.00 (5 Aug 2010); $20,716.05 (16 Sep 2010); $20,000.00 (2 Nov 2010); $8,117.51 (26 Jan 2011); $2,295.50 (28 Apr 2011, invoice 1335143 together with a TMS Services invoice numbered 803674); $11,979.25 (2 Feb 2012, invoices 1404109 and 1395117); $20,000.00 (11 Sep 2012, invoices 1444343 and 1444344); $252.00 (9 Nov 2012, invoice 1459189); $2,145.60 (26 Dec 2012, invoice 1462781); $279.45 (25 Jan 2013, invoice 1476612); $1,440.00 (5 Mar 2013, invoice 1482491); $848.75 (24 Apr 2013, invoice 1493452); $391.86 (26 Jun 2013, invoice 1506343). Total $113,465.97. With the two Deutsche Bank payments the total is $162,876.56 across fifteen distinct transactions and at least eighty-four documents, most transactions appearing two or three times in different Bates families: the statement copies, the fax-confirmation copies and the request-form copies. ⚠ The 74 documents returned by a search for the client number are not a census of the payments and must not be quoted as one; two payments carry no reference field at all. ⚠ One sheet in the release would break this table if read by position: a wire-request form for invoice 1482491 sits directly above the head of a different form for a payment of $4,850.00 to another firm, so reading down the page pairs the Troutman invoice with the wrong amount. The correct figure, $1,440.00, is confirmed by a separate request form and by three statement copies, and the two transactions carry distinct Imads. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  21. Deutsche Bank Private Wealth Management funds-transfer authorisation, beneficiary “Troutman Sanders LLP”, additional instructions “BJ Moskowitz Client #: 238227” and “Invoice #: 1552207”, print name “Harry Beller”, dated in manuscript 2-4-2014 over a wet signature. EFTA01360227 p.1, with a second copy at EFTA01403625 p.1. Read at the image. It executed: a matching debit of $450.00 appears on the February 2014 Deutsche Bank statement, EFTA01284740 p.2. Invoice 1552207 is numbered above any invoice in the JPMorgan series and the date is seven and a half months after the last of those wires, so the payments continued across Epstein’s move from JPMorgan to Deutsche Bank. ⚠ The link between the authorisation and the statement debit rests on date, amount and payee rather than on a printed client reference in the statement line; that is a strong inference and is not stated here as a documented identity. What is documented is that Epstein’s office authorised, and a Deutsche Bank account paid, Troutman Sanders on the Moskowitz client file after the JPMorgan relationship ended. ↩ ↩2

  22. Deutsche Bank Trust Company Americas statement for an account in Epstein’s name, recording “10-31 # Outgoing Money Trnsf (48,960.59) TO WELLS FARGO BANK, NA … TROUTMAN SANDERS LLP”. EFTA01287941 p.4. Read at the image; the balance arithmetic on the sheet checks, 4,236,567.82 − 48,960.59 = 4,187,607.23. This statement line carries no client reference, so the connection to the Moskowitz file rests on the amount matching invoice 2040188 exactly and on the payee; a full-text search for the figure returns only this statement and the invoice. Account numbers on the sheet are not reproduced. ↩ ↩2

  23. JPMorgan statement for Jeffrey E Epstein, period 31 July 2010 to 31 August 2010, transaction detail for 5 August 2010. EFTA01483234 p.1. Prints, in order, a $50,000.00 fedwire debit to “Martin G Weinberg P C” referenced “IOLTA Ref RefJune And July Invoices”; a $25,000.00 fedwire debit to “Troutman Sanders Lip” referenced “Ref: Ref B J Moskowitz Client 238227”; and a $25,000.00 fedwire debit to “Black Srebnick Kornapan And Stref: P A” referenced “Statement 57/Acc/Trust Acct No 2 No Name Given”. The firm names are as extracted; “Lip” is “LLP” and “Kornapan And Stref” is Kornspan & Stumpf. The sheet’s own footer reads “Page 2 of JO”, i.e. page 2 of 10, so the single-page EFTA document is an interior sheet of a longer statement. A near-duplicate copy of the same sheet sits at EFTA01483224 p.1 with heavier extraction damage. ↩ ↩2 ↩3 ↩4 ↩5

  24. JPMorgan statement, period 1 June 2013 to 28 June 2013. EFTA01483803 p.1. Records a $391.86 fedwire debit on 26 June 2013 to “Troutman Sanders Up” referenced “B J Moskowitz Client 238227 Invoice1506343”. ↩

  25. Memorandum on “JEFFREY E. EPSTEIN” letterhead, fax-stamped “Aug-05-2010 02 08 PM JPMorgan Chase”, instructing the bank to “Please wire Twenty Five Thousand Dollars & 00/100 ($25,000.00) from the above account” to Troutman Sanders LLP, “Reference: B J Moskowitz — Client 238227”, and closing “Please call Rich Kahn with the Fed Reference number”. EFTA01581597 p.1. Account numbers printed on the sheet are not reproduced here. The author of these memoranda has not been settled at the image and is under check; one sheet in a longer run carries a “From: Harry Beller” line. EFTA01591683 p.12. ↩ ↩2

  26. Memorandum, fax-stamped “Sep-16-2010 04:04 PM JPMorgan Chase”, instructing a wire of “Twenty Thousand Seven Hundred Sixteen Dollars & 05/100” to Troutman Sanders LLP against the same reference, closing “Please call Rich Kahn with the Fed Reference number”. EFTA01581569 p.1. ↩

  27. Memorandum, fax-stamped “Nov-02-2010 12:11 PM JPMorgan Chase”, instructing a wire of “Twenty Thousand Dollars & 00/100” to Troutman Sanders LLP against the same reference, closing “Please call Rich Kahn with the Fed Reference number”. EFTA01581496 p.1. ↩

  28. Nine payment instruments were read at the image for authorship. Seven carry “From: Harry Beller” and two “From: Darren Indyke”, the two being the memorandum for the first wire of 5 August 2010 and the memorandum for the 26 January 2011 payment of the invoice flagged in Kahn’s list. The recipients named are officers at JPMorgan. Instruments include EFTA01581597 p.1, EFTA01581569 p.1, EFTA01581496 p.1, EFTA01581400 p.1 and EFTA01581283 p.1. Account numbers printed on these sheets are not reproduced. ↩

  29. Rich Kahn to Jeffrey Epstein, Tuesday 18 January 2011, 3:41:37 PM, subject “re: Open Items”. EFTA01990161 p.1. Item (h) of a lettered list. This copy’s text layer renders the figure “8,1 17 5 1”, with spaces inserted and the decimal point lost, so the document cannot be found by searching for “8,117.51”; the parenthetical “(pd to date: 65,716.05)” is intact. Other items on the list name private individuals in connection with household and personal matters and are not reproduced here. ↩ ↩2

  30. A second copy of the same email, timed 3:42 PM. EFTA01792188 p.1. This copy’s text layer renders the figure ”=,117.51”, the leading digit replaced by a stray character from the message’s own quoted-printable encoding, and carries similar damage throughout (”=/span>” in place of markup). Neither copy is reachable by a search for the figure itself. ↩ ↩2

  31. JPMorgan statement, period 30 October 2010 to 30 November 2010. EFTA01483294 p.1. Records a $20,000.00 fedwire debit on 2 November 2010 to “Troutman Sanders Up” referenced “Ref Ref B J Moskowitz Client 238227”. ↩

  32. Memorandum, fax-stamped “Jan-26-2011 03:01 PM JPMorgan Chase”, instructing a wire of “Eight Thousand One Hundred Seventeen Dollars & 51/100 ($8,117.51)” to Troutman Sanders LLP, “Reference: B J Moskowitz — Client 238227”, closing “Please call Rich Kahn with the F[ed Reference number]”. EFTA01581400 p.1. A second copy sits at EFTA01591542 p.1. ↩

  33. JPMorgan statement, period 1 January 2011 to 31 January 2011. EFTA01483333 p.1. Records an $8,117.51 fedwire debit on 26 January 2011 to “Troutman Sanders Up” referenced “Ref: B J Moskowitz Client 238227”, taking the balance from $2,899,495.58 to $2,891,378.07. The sheet’s footer reads “Page 4 of 8”. ↩

  34. Spreadsheet headed “Jeffrey Epstein — Outstanding Legal Invoices”, five sheets, the latest invoice month appearing on it being 31 October 2010. EFTA00727857 p.1 for the itemised Troutman Sanders block and p.4 for the firm’s summary row. Read at the image. The itemised block runs from the invoice month 31 May 2010 and shows, month by month, billed and credited amounts of 15,500.75/−10,968.10, 32,914.12/−25,000.00, 8,269.28/−20,716.05, 22,612.95/0.00 and 3,536.49/−20,000.00, with a total billed of 82,833.59 against credits of 76,684.15. The only credit preceding the June 2010 invoice is the write-off, so no fourth earlier payment appears on the face of the contemporaneous ledger. The final column of the summary row reads 8.56%; the document does not state what it is a percentage of, and no interpretation is offered here. ↩ ↩2 ↩3 ↩4 ↩5

  35. The Mintz Fraade Law Firm, P.C. to the Hon. Richard J. Sullivan, 1 July 2016, filed as Document 22 in No. 1:16-cv-03989-RJS, withdrawing Hoffenberg v. Epstein. EFTA00594947 p.1. Read at the image at 250 dpi for the account at Towers Financial Corporation: a single unredacted sheet carrying the court’s electronic filing header, signed in manuscript above the typed name Alan P. Fraade, with a copy block naming Gary H. Baise, Esq., Mr. Steven Hoffenberg and Bennet J. Moskowitz, Esq. ↩

  36. Fee narrative, same invoice. EFTA00804463 p.2. A method note, because it bears on how far this sheet can be trusted. On this sheet the date-and-initials column, the description column and the hours-and-amount column each extract as one contiguous vertical run, so position does not pair them and the corpus text layer cannot be read by row at all. The desk first recovered the pairing by dividing each amount by its hours and matching the implied rate against the initials sequence, which reproduced across all fifteen rows of this sheet. That is a consistency check and not an identification, and it is not a sound method in general: the invoice’s own summary shows two timekeepers billing at the same rate, so a rate does not uniquely name a row. The pairings relied on here, and in particular the attribution of the row recording the drafting of his declaration, were settled by reading the sheet at the image rather than by arithmetic. The fifteen-row count is for this sheet only; the narrative continues on p.3. ↩ ↩2 ↩3

  37. The signature block for Bennet J. Moskowitz on the Gerber memorandum of law. EFTA00802452 pp.24-25. UNVERIFIED at the image: recorded at Towers Financial Corporation as taken from a search hit, with whether the signature is manuscript or the electronic “/s/” form the extraction shows not settled. ↩

  38. Marvin Gerber and Kalma Koenig, on behalf of themselves and all others similarly situated, v. The Financial Trust Company, XYZ Corporation, ABC, Inc., and Jeffrey E. Epstein, No. 1:18-cv-07580-JPO (S.D.N.Y.), filed 20 August 2018, voluntarily dismissed without prejudice 5 October 2018. Case history, pleading and dismissal are set out with their citations at Towers Financial Corporation. ↩

  39. Sheet headed “DRAFT; PRIVILEGED; ATTORNEY WORK PRODUCT” above the caption of Marvin Gerber and Kalma Koenig … v. The Financial Trust Company, XYZ Corporation, ABC, Inc., and Jeffrey E. Epstein in the Southern District of New York. EFTA00800143 p.1. ↩

  40. A second sheet carrying the same legend above the same caption. EFTA00806706 p.1. ↩

  41. Same letter. EFTA00023230 p.2. ↩

  42. Same letter, signature and copy list. EFTA00023230 p.3. ↩

  43. Five declarations of his are in the release, listed with their identifiers at 6, 7, 8, 44 and 9. Four exist as filed originals; the earliest is present only as a privileged internal draft. An absence check for an as-filed 14 September 2018 copy returned none, with positive controls: a phrase search on a distinctive exhibit line returns the draft and one unrelated document, and a search on a distinctive term in the draft returns only the draft and the brief that cites it. ↩ ↩2

  44. Declaration of Bennet J. Moskowitz dated 11 May 2020, ECF Document 41 in No. 1:20-cv-00484-JGK-DCF (S.D.N.Y.). EFTA02752060 pp.1-2. It places before the court the opinions and orders entered in two earlier actions against the estate, captioned under the pseudonyms Mary Doe and Jane Doe 15; a brief in the same matter describes them as its Exhibits A and B. EFTA02752022 p.7. ↩ ↩2

  45. Same covering letter. EFTA02752620 p.1. Read at the image. Verbatim: “The unredacted and redacted versions of the Statement and accompanying Declaration of Bennet J. Moskowitz are being filed under seal and publicly, respectively, contemporaneously herewith in accordance with Individual Practices § (III)(B).” ⚠ “Respectively” pairs with “the unredacted and redacted versions”, not with “Statement and Declaration”: both documents were filed twice, unredacted under seal and redacted publicly. A reading that sealed the statement and made the declaration public would be wrong. The letter’s own footnote 1 says what was sealed outright: “The exhibits to the Declaration are filed entirely under seal.” The stated purpose of the redactions is “to ensure Plaintiff’s identity is not made public pending the Court’s determination of her Application”. ↩ ↩2

  46. Covering letter of the co-executors, ECF Document 33 in No. 1:20-cv-02365-LJL-DCF (S.D.N.Y.), filed 13 August 2021. EFTA02752626 p.2, at footnotes 2 and 3 of that letter. Read at the image. The quoted sentence is footnote 2 in full, and it carries no citation and no exhibit. Footnote 3 hangs off the preceding sentence, which gives the programme’s awards as “nearly $125 million to approximately 150 eligible claimants”, and reads: “See [a link to the programme’s own document page] (The Declaration of Bennet J. Moskowitz, filed contemporaneously herewith, provides true and correct copies of all ▮▮▮)”. The tail of that parenthesis is closed by a redaction bar running to a visible closing bracket, so what the declaration authenticated is not established and is not guessed at here. The link’s domain is mangled in the text layer and the corrected form is not reproduced. An earlier reading by this desk, and a first reading by the pass that checked it, both attached the declaration to footnote 2; the image refutes both. ↩ ↩2 ↩3

  47. Epstein Victims’ Compensation Program protocol dated 29 May 2020, quoted with its citation at the Epstein Victims’ Compensation Program, which is this wiki’s account of the programme, its protocol, its funding and its published closing figures. The protocol term is independent of the 2021 filing discussed here and was in force a year before it. ↩

  48. Kaplan Hecker & Fink LLP to the Hon. Katherine Polk Failla, 31 October 2019, in Doe v. Indyke et al., No. 19-cv-08673 (KPF) (S.D.N.Y.), Document 14, filed 31 October 2019. EFTA02750898 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  49. A second copy of the same letter, stamped “MEMO ENDORSED”, Document 17, filed 1 November 2019. EFTA02750903 p.1. Whether the two copies differ beyond the endorsement stamp has not been settled. ↩

  50. Bennet J. Moskowitz, Troutman Sanders LLP, to the Hon. Katherine Polk Failla, 29 October 2019, in Jane Doe v. Indyke and Kahn, No. 1:19-cv-08673-KPF-DCF (S.D.N.Y.), ECF Document 13, “Page 1 of 1”. EFTA02750881 p.1. Read at the image. Signed “s/Bennet J. Moskowitz”. Three solid bars on the face of the sheet each cover a single character, a middle initial, at the three places the bars appear in the quotation above. Nothing is recovered from them here. The bars are applied to one of the two named co-executors and not the other, which is a mechanical inconsistency in the production and is recorded as such; no location for any instance of that character elsewhere is given. The docket number of the other action prints as “1:19-cv-0777”, one digit short, confirmed at 600 dpi. ↩ ↩2 ↩3 ↩4

  51. Bennet J. Moskowitz to the Hon. Katherine Polk Failla, 5 November 2019, same action, ECF Document 20, signed “s/Bennet J. Moskowitz”. EFTA02750909 pp.1-2. Read at the image. A related letter of the same date, ECF Document 19, footnotes six further Southern District actions by name and number and states that the group “so far include 7 different plaintiffs and 20 different defendants”. EFTA02750907 p.1. ↩ ↩2 ↩3 ↩4

  52. “DEFENDANTS’ MEMORANDUM OF LAW IN RESPONSE TO PLAINTIFF’S MOTION FOR LEAVE TO PROCEED UNDER PSEUDONYM”, same action, ECF Document 31, filed 15 November 2019, signed “By:/s/ Bennet J. Moskowitz”. EFTA02750939 p.2, the opening of the ARGUMENT section; the quoted passage is on p.2 of the four-sheet run. Read at the image. Later in the same brief, at p.4, it cites Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, Doe v. Skyline Automobiles, 375 F. Supp. 3d 401, and Doe I v. Four Bros. Pizza for the proposition that a plaintiff’s anonymity may prejudice a defendant; a pin check searching this footnote’s strings will find those authorities on p.4 and report p.2 as wrong, which it is not. ↩

  53. Proposed “ORDER ON PLAINTIFF’S ANONYMITY”, same action, ECF Document 31-1. EFTA02750938 p.1. Read at the image. The paragraph quoted is its third. ↩ ↩2

  54. Plaintiff’s reply, same action, ECF Document 34, filed 19 November 2019. EFTA02750945 p.2. ↩ ↩2

  55. Same reply. EFTA02750945 p.3. ↩

  56. EFTA02750869 p.1, ECF Document 9 in No. 1:19-cv-08673-KPF-DCF, recording the plaintiff’s consent on 24 September 2019 to the schedule under which the co-executors would respond by 15 November 2019. ↩

  57. “JOINT STIPULATION AND [PROPOSED] ORDER ON PLAINTIFF’S ANONYMITY”, same action, ECF Document 41, filed 18 December 2019, reproducing ECF Document 38 dated 13 December 2019, “SO ORDERED” 18 December 2019 by the Hon. Debra Freeman, United States Magistrate Judge. EFTA02750989 pp.1-2. Read at the image: both signature blocks appear on one instrument, his over “TROUTMAN SANDERS LLP, Attorneys for Defendants Darren K. Indyke and Richard D. Kahn” with a manuscript signature initialled “BJM /KLD”, alongside three lawyers for the plaintiff. The signature blocks print telephone numbers and e-mail addresses for counsel on both sides in the clear; none is reproduced here. ↩ ↩2 ↩3

  58. Bennet J. Moskowitz to the court in No. 1:19-cv-07625-AJN-DCF (S.D.N.Y.), ECF Document 25, filed 29 October 2019, the same day as 50 and in nearly identical wording, carrying the same “1:19-cv-0777” miscite. EFTA02846126 p.1. Read at the image. The letter also asks the court to approve an agreed extension to 15 November 2019, noting “This is the first request regarding this deadline.” That action was later dismissed with prejudice on 7 December 2020, following the plaintiff’s resolution of her claims through the Epstein Victims’ Compensation Program, on a stipulation signed for the estate by Molly S. DiRago. ↩

  59. Exhibit A to the letter motion at 48, being the parties’ correspondence, ECF Document 14-1, sixteen sheets, including letters from Moskowitz dated 22 and 28 October 2019 and the intervening e-mail thread. EFTA02750882 pp.1-16. ↩

  60. Bennet J. Moskowitz to the court in Jane Doe 17 v. Indyke and Kahn, No. 1:19-cv-09610-PAE-DCF (S.D.N.Y.), ECF Document 27, filed 20 November 2019. EFTA02738030 pp.1-2, the signature being on p.2 of the two-sheet run. Read at the image. The same sheet names his clients in that action as Indyke and Kahn together with Nine East 71st Street, Corporation; Financial Trust Company, Inc.; NES, LLC; Laurel, Inc.; Maple, Inc.; LSJE, LLC; HBRK Associates, Inc.; Nautilus, Inc.; Cypress, Inc.; and JEGE, Inc. Whether the Financial Trust entity named there is the same legal person as the defendant in the 2018 Gerber matter has not been tested and is not asserted. ↩ ↩2

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